G.R. No. 229926 April 3, 2019
PEOPLE OF THE PHILIPPINES, Appellee vs. PERIGRINA CADUNGOG, Appellant

FACTS

The prosecution established that based on a tip, a buy-bust operation was conducted against appellant Perigrina Cadungog for selling illegal drugs. PO1 Romeo Caacoy acted as poseur-buyer and purchased two plastic sachets of shabu from Cadungog for PHP 500. Upon consummation of the sale, Cadungog was arrested. The seized items were marked at the scene, and an inventory was conducted in the presence of barangay neighbors who signed the receipt. The items were then brought to the police station, a request for examination was prepared, and the sachets were delivered to the crime laboratory, where they tested positive for methamphetamine hydrochloride.
The defense presented a starkly different version. Cadungog testified that while cooking at home, persons not in uniform forcibly entered her house, dragged her to a police vehicle, and brought her to the station. There, she was shown plastic sachets and falsely accused of owning them. She denied any involvement in a drug sale.

ISSUE

Whether the prosecution proved the guilt of the appellant for illegal sale of dangerous drugs beyond reasonable doubt, particularly with respect to the chain of custody of the seized items.

RULING

Yes. The Supreme Court affirmed the conviction. The core issue in drug-related cases is whether the identity and integrity of the corpus delicti have been preserved with an unbroken chain of custody. The Court found that the prosecution successfully established all links: first, the seizure and marking of the drugs immediately after the buy-bust; second, the turnover to the investigating officer; third, the delivery to the forensic laboratory; and fourth, the submission to the court. While the strict procedural requirements under Section 21 of RA 9165, such as the presence of specific witnesses during inventory, were not perfectly followed, the Court ruled that the integrity of the evidence was nevertheless preserved. The marking and inventory were done at the place of arrest in the presence of barangay neighbors, and the chain of custody records showed no gaps or evidence of tampering. The defense of frame-up was rejected for being uncorroborated and failing to present clear and convincing evidence of any ill motive on the part of the police officers. The testimonies of the apprehending officers were deemed credible and consistent. Thus, the elements of illegal sale of dangerous drugs were proven beyond reasonable doubt.